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Annual Verification Audit Protocol for Green-e® Direct Participants

Reporting Year 2018

Center for Resource Solutions1012 Torney Ave., 2nd FloorSan Francisco, CA 94129415-561-2100 | www.resource-solutions.org | www.green-e.org

Copyright © February 2019 Center for Resource Solutions. All rights reserved.

Table of Contents

I. OVERVIEW 4

1. PROPRIETARY INFORMATION & LEGAL NOTICE 42. OBJECTIVES OF THE ANNUAL VERIFICATION INSTRUCTIONS 53. SUMMARY REQUIREMENTS 53. HOW TO GET HELP 5

II. GENERAL VERIFICATION AUDIT PROVISIONS 6

1. SCOPE OF VERIFICATION AUDIT 62. AUDITOR QUALIFICATIONS 63. FORM OF ENGAGEMENT AND REPORT 64. USE OF RENEWABLE ENERGY CERTIFICATES IN ELECTRICITY PRODUCTS 75. SCOPE OF TESTING 86. PERIOD COVERED BY REPORTING REQUIREMENTS 97. DEADLINE FOR SUBMITTING THE ANNUAL VERIFICATION SUBMISSION 98. USE OF SAMPLING TECHNIQUES 99. TESTS OF ATTRIBUTES 1110. PRINCIPAL TESTING TO BE PERFORMED 1111. APPLYING GENERAL PROCEDURES TO SPECIFIC CIRCUMSTANCES 11

III. SPECIFIC AUDIT REQUIREMENTS 11

1. SUPPLY AND SUPPORTING DOCUMENTATION 14Background and Important Reminders for the Section 15

2. GREEN-E® ENERGY CERTIFIED RETAIL SALES 27

APPENDIX A: GLOSSARY OF TERMS 30

APPENDIX B: DOCUMENTS AND INFORMATION NEEDED BY THE AUDITOR AND GREEN-E® ENERGY 33

APPENDIX C: INTENTIONALLY OMITTED 39

APPENDIX D: ATTESTATION REQUIREMENTS 40

APPENDIX F: COMPANIES PARTICIPATING IN GREEN-E® ENERGY IN 2018 51

Copyright © February 2019 Center for Resource Solutions. All rights reserved.

I. OVERVIEWThis document, the Green-e® Energy Annual Verification Audit Protocol (“Protocol”), addresses the annual verification reporting requirements for companies participating in Green-e® Energy. The term “Participant” as used in this document refers to a company with one or more contracts with Center for Resource Solutions to procure and certify renewable energy products on its own behalf. The Protocol describes how auditors hired by or employed by Participants should conduct an independent verification audit as required by Green-e® Energy to support the Participant’s annual verification of certified products. The audit covers all Green-e® Energy certified renewable energy products used in a calendar year, referred to as the Reporting Year (“RY”).

The audit must be documented in an Agreed-Upon Procedures Report. This report and the entire Green-e® Energy Annual Verification Submission (“Verification Submission”) must be received at Center for Resource Solutions (CRS) no later than the due date listed in the Participant’s contract with Center for Resource Solutions, and must be submitted through the Green-e® Energy verification software system.

The verification process is as follows.

Participants must use the verification software to submit supply data, attestations, and all other applicable required documents. Participants must provide these and supporting documentation to an independent certified public accountant or certified internal auditor (“Auditor”).

The Auditor then follows the Protocol to verify the accuracy of the information provided by the Participant.

The Auditor’s Agreed-Upon Procedures Report, the Participant’s supply data and attestations, and other supporting documents identified in the Guide are submitted to CRS through the verification software for final review and acceptance. These data and documents are collectively called the Annual Verification Submission.

For RY2018 verification, all data submission and review will take place in the Green-e® Energy verification software tool; for more information on this system, please see Section I of the Getting Started Guide, available in the “Verification Documents” tab within the verification software tool.

1. Proprietary Information & Legal Notice

This document and the information contained in it is proprietary and confidential information of Center for Resource Solutions (“CRS”) and may not be reproduced, copied in whole or in part, adapted, modified, disclosed to others, or disseminated without the prior written permission of CRS. Use of this document and the information contained in it is strictly reserved for current CRS personnel and Green-e® Participants that have a current certification contract in effect with CRS and is subject to the terms and conditions of the Participant’s contract for Green-e® certification, including its provisions on confidentiality. Use of this document by unauthorized persons is strictly prohibited. Report violation of these requirements to CRS’s Green-e® program staff. This

Copyright © February 2019 Center for Resource Solutions. All rights reserved.Page 3 of 50

document must be returned to CRS if the Participant no longer has an active contract for certification and in any event upon CRS’s first written request.

2. Objectives of the Annual Verification InstructionsThe primary objectives of the Protocol are to provide guidance to Auditors regarding the audit and review procedures necessary to produce a satisfactory Agreed-Upon Procedures Report.

The Protocol addresses Green-e® Direct renewable energy certification offered by Center for Resource Solutions.

3. Summary Requirements Each Green-e® Energy certified renewable energy product of the Participant must undergo verification procedures annually. These procedures confirm the amount and eligibility of renewable MWh purchases and/or generation. The information checked through these procedures includes:

1. Supply – the Participant generated or purchased eligible renewable resources as defined by the Green-e® Energy Renewable Energy Standard for Canada and the United States (“Standard for Canada and the US”), and these purchases or generation are accurately reported by the Participant.

2. The eligible renewable MWh represented in the product were not used for compliance with any procurement, renewable portfolio standard (RPS) or other renewable energy requirement of local, state, or federal government. The sole exception is a facility that is generating renewable energy in excess of the government mandate or other legal contract, in which case the excess renewable MWh may be used in a Green-e® Energy certified product, as provided for in the Green-e® Energy Standard for Canada and the US.

3. The Green-e® Energy certified product only contained MWh of the appropriate vintage, or generation period. Eligible MWh must be generated in the calendar year in which the product was sold, the first three months of the following calendar year, and/or the last six months of the prior calendar year.

4. All the attributes of the renewable energy, as defined in the Standard for Canada and the US (including CO2 benefits), were fully aggregated and not sold off separately, and were not resold by the Participant.

5. The generator and/or seller of the renewable MWh has no knowledge of double counting, double selling or double claiming of the renewable MWh, and the renewable attributes of the generation were sold to a single buyer in each transaction.

Criteria Applicable only for Products Wholly or Partially Supplied by RECs:1. The electrical energy associated with RECs was delivered into the electric power system or

consumed at the site of generation by a grid-connected end-user of electricity and was not marketed or otherwise represented as renewable electricity.

3. How to Get HelpShould assistance be required, Center for Resource Solutions staff is available to answer questions. Questions relating to verification may be directed to Green-e® staff at 415-561-2100


or [email protected]. Electronic copies of attestations and many other verification documents are available on our website, at http://www.green-e.org/verif_docs.html; electronic copies of this document, the Guide, and training materials for Participants and Auditors are available only to these entities, through the Green-e® Energy verification software system.

Additionally, Green-e® Energy staff hosts training calls for Auditors, to go through various aspects of verification and answer questions. These calls typically happen in the spring of the year following the Reporting Year being verified, and all Green-e® Energy Participants undergoing verification will be contacted in advance regarding such calls; Auditors should request that the Participant that has engaged them to conduct the annual verification audit pass along training call scheduling.

II. GENERAL VERIFICATION AUDIT PROVISIONS

1. Scope of Verification Audit The verification audit addressed in the Guide and Protocol is for the annual verification reporting requirements of Green-e® Energy. This guidance is to be used by Participants and their Auditors. CRS acknowledges that the procedures put forward in the Protocol are sufficient when performed in their entirety. Satisfactory completion of the procedures described in the Protocol is not, however, sufficient for verification of adherence to the Green-e® Energy Code of Conduct and Customer Disclosure Requirements, which is verified through a separate Marketing Compliance Review process.

2. Auditor QualificationsParticipant must engage an independent certified public accountant to perform this process audit engagement and report on agreed-upon procedures in accordance with the American Institute of Certified Public Accountants (AICPA) Statements on Standards for Attestation Engagements, Number 18, Attestation Standards: Clarification and Recodification AT-C Section 105, Concepts Common to All Attestation Engagements or under AT-C Section 215, Agreed-Upon Procedures Engagements. Alternatively, the Participant may elect to have their internal audit department (or the internal audit department of an affiliated company) perform the procedures enumerated in Section III, provided that the individual accountant signing the Agreed-Upon Procedures Report for the internal audit department is a Certified Internal Auditor in good standing with the Institute of Internal Auditors (IIA) at the time of the audit; the internal auditor being a CPA is not sufficient in this case. The CIA must not be the same person that prepares or submits verification data and accompanying documents (Annual Verification Submission) through the Green-e® Energy verification software system for the Participant for review. The term “Auditor” in this document refers to an independent certified public accountant or a certified internal auditor that meets the criteria above.

3. Form of Engagement and ReportThe form of the report should specify the procedures performed and findings in a manner similar to reporting under AT-C Section 105 or AT-C Section 215 of the AICPA’s attestation or auditing standards, respectively. The Auditor should make reasonable efforts to ensure that the report is


prepared in accordance with these minimum standards. In accordance with paragraph .41 of AT-C Section 215 (in which “practitioner” is equivalent to “Auditor”),

[a]lthough the practitioner need not perform procedures beyond the agreed-upon procedures, if in connection with the application, and through the

completion of, the agreed-upon procedures engagement, matters come to thepractitioner's attention by other means that significantly contradict the subjectmatter or assertion referred to in the practitioner's report, the practitionershould include this matter in the practitioner's report.

The Participant may elect a higher level of assurance with regard to its reporting requirements conducted by an Auditor. CRS welcomes attestation or similar audit-level assurance with regard to the information, forms and assertions described in this document. Such alternative reporting must be discussed with CRS staff prior to submission of the Agreed-Upon Procedures Report.

The Agreed-Upon Procedures Report must be submitted through the verification software system,

If Green-e® Energy staff find that the Agreed-Upon Procedures Report is not completely filled out, the Participant’s Annual Verification Submission will not be considered complete until the Agreed-Upon Procedures Report is satisfactorily revised to reflect that the full audit was conducted in accordance with this Protocol.

Auditors that do not provide a satisfactory Agreed-Upon Procedures Report will not be eligible to be listed on the list of auditors on the Green-e® website (http://www.green-e.org/auditors.html), may be removed from that list if the Auditor has appeared on it in the past, may be placed on probation, and may be barred from performing future Green-e® Energy audits, at the sole discretion of Green-e® Energy staff. For Auditors placed on probation, should the quality of the subsequent year’s Agreed-Upon Procedures Reporting not improve, the Auditor may be deemed unacceptable to perform the Green-e® Energy Annual Verification Audit thereafter.

4. Use of Renewable Energy Certificates in Electricity ProductsRenewable electricity generation may be characterized as having a commodity electricity attribute and a separate renewable attribute. Hence, for each MWh of eligible renewable electricity generated, a corresponding MWh of renewable attribute is generated. This renewable attribute may be separately documented from the commodity electricity through the use of a REC that the generator may then sell separately from the commodity electricity. Once the renewable attribute of eligible generation has been separated from the corresponding commodity electricity through the sale of RECs, the commodity electricity can no longer be claimed as qualifying renewable generation under Green-e® Energy. However, the REC may be used to substantiate an eligible renewables purchase for the purpose of substantiating a later Green-e® Energy certified renewable electricity sale (i.e., as Competitive Electricity Products or Utility Green Pricing Products), provided the conditions below are satisfied.1

1 Once the eligible REC is sold separately from the commodity electricity, the commodity electricity becomes generic, undifferentiated, “null” or system mix power. The commodity electricity may not be sold as a specific renewable purchase unless an eligible REC matches it. Further, each MWh represented by an eligible REC may be sold or associated with electricity sales to only one end-use customer.


1. The REC must represent electricity that is from a generator that meets the eligibility requires in the Standard for Canada and the US.

2. The REC must represent electricity that is from a generator that is located within the same defined geographic sourcing boundary or power pool as the customer. Or, if the generator is outside the boundary or power pool, the Participant delivering the REC with electricity as a certified renewable electricity product must demonstrate that an amount of electricity equal to the number of RECs was delivered into the defined geographic sourcing boundary or power pool in which the retail product that contains the REC is sold, and that this electricity is only being allocated to the particular certified sale. See Section IV.B of the Standard for Canada and the US for more details.

3. Chain of custody of the RECs must be documented using attestations and contracts, or Electronic Tracking System Reports (“Tracking System Reports”).

4. Eligible RECs may be traded without restriction at the wholesale level among generators and REC wholesalers and remain eligible under Green-e® Energy when matched with commodity electricity sold to an end-use customer. However, RECs that are sold to end-use customers without matching commodity electricity are not eligible under Green-e® Energy electricity certification. To qualify as certified product under Green-e® Energy electricity certification, a Participant must purchase RECs and purchase and deliver a like amount of commodity electricity with those RECs.

5. Scope of Testing

The Participant’s management will need to make certain decisions regarding the scope of testing. This is due to the guidance involving agreed-upon procedures conducted in accordance with the AICPA, at Section AT-C 105 or Section AT-C 215, which results in an Auditor’s report that is in the form of procedures and findings and not in the form of an opinion or negative assurance. Additionally, the specified users of the agreed-upon procedures report are responsible for the sufficiency (nature, timing and extent) of the agreed-upon procedures, and assume the risk that such procedures might be insufficient for their purpose or that they might misunderstand or inappropriately use findings properly reported by the Auditor.

CRS has attempted to provide a Protocol that requires limited decisions necessary from the management of the Participant company or from the Auditor; however, if questions regarding the scope arise, please contact Green-e® Energy staff for guidance, and for approval of any changes that may be necessary to address scope issues.

6. Period Covered by Reporting Requirements The Agreed-Upon Procedures Report must be prepared for Green-e® Energy on a calendar year basis. For those companies enrolling in Green-e® Energy in the middle of a Reporting Year (“RY”), the reports should be prepared for the period starting on the date the Participant signed


their Green-e® Energy contract and ending on December 31 of the RY, or alternatively for the full RY with prior written permission of Green-e® Energy staff.

7. Deadline for Submitting the Annual Verification Submission The due date for all verification materials being received by CRS is provided listed in the Participant’s contract with Center for Resource Solutions and will be displayed in the Auditor’s account within the Green-e® Energy Verification Tool. The Agreed-Upon Procedures Report, along with all relevant documents listed in Appendix B, must be received by CRS through the Green-e® Energy verification software system on or before this date.

Any additional materials that cannot be submitted through the verification software should be emailed to [email protected] on or before this date as well. No hardcopies are required, unless by specific request by Green-e® Energy staff.

8. Use of Sampling TechniquesIn certain procedures in Section III of the Protocol, the Auditor may use sampling techniques to test the attributes of the Participant’s data. Sampling criteria have been established by CRS to be followed in the performance of the agreed-upon procedures. Additionally, the Participant and the Auditor will need to make certain decisions and judgments in the process of establishing the appropriate sample size, following the guidance set forth in the AICPA AU Section 350, Audit Sampling. CRS will allow alternative methods to determine sample size than what is given below, provided that the resultant sample size is greater than or equal to that which results from the method below. If the Auditor chooses not to use approved sampling techniques or an alternative method that results in greater or equal sampling size, then 100% of the population must be tested.

CRS has determined that an attributes sampling methodology is most appropriate given the characteristics of the populations for which sampling is utilized in the agreed upon procedures. Attributes sampling is used to reach a conclusion about a population in terms of the rate of occurrence of a certain attribute. For the purposes of sampling, an attribute is defined as a characteristic that is either present or absent in a sampling unit. Each sampling event required in the agreed upon procedures will identify the applicable sampling unit. However, in general the sampling unit for sales is each individual sale transaction, donation, or other transaction that conveys or retires renewable electricity or RECs to the benefit of another party, and for supply is a quarter of renewable electricity generation from a particular generating facility. Each occurrence (the presence or absence of an attribute) is given equal weight in the sample evaluation, regardless of the size of the transaction. In any event, no more than 50 percent (50%) of the selected transactions may relate to any one month unless more than 50 percent (50%) of the population relates to the same month. All parameters and deviations used and the sample size itself must be described in the report in the relevant steps in Section III below.

If the Auditor elects to utilize sampling techniques rather than test 100% of the population, they must first ascertain the population size. The population size is defined in terms of the number of sampling units. If the population is greater than or equal to 2,000 transactions, the Auditor will utilize Table A-1 in Appendix A of the AICPA Audit Guide on Audit Sampling. The Auditor will determine the sample size based on 5% risk of overreliance, tolerable deviation rate of 10% and


expected deviation rate of 3%. If the population is less than 2,000 transactions, then the Auditor will utilize the table below to determine the appropriate sample size.

Population Sample Size

1-19 Same as population size

20-25 1926-30 2131-40 2541-50 2851-60 3161-70 3471-80 3681-90 37

91-100 39101-120 42

Population Sample Size121-140 44141-160 45161-180 47181-200 48201-300 52301-400 54401-500 56501-600 57601-700 58

701-1000 591001-1999 60

The table above was created by using statistical attribute sampling software using the above guidance.

Once the appropriate sample size has been determined, the sample selection should be made on a random basis with a random number generator or similar process as the preferred approach. Other sample selection methods (e.g., systematic), are acceptable, provided the resultant selection is ultimately random in nature (e.g., each member of the population has an equal chance of being selected). In any event, no more than 50% of the selected transactions may relate to any one month unless more than 50% of the population relates to the same month (in which case this should be included in the notes section of the applicable area of the agreed upon procedures report).

Once testing is complete, the Auditor must evaluate the results of the testing to ensure the objectives of the test were met. If a greater number of deviations are found than were planned for, then the test objective has not been met and there is a high risk that the deviation rate in the population exceeds the tolerable deviation rate. If the number of deviations noted in the initial sample selection exceeds 3%, then an additional sample must be selected. The additional sample should equal the lesser of the initial sample size or the remaining items in the population. Once the additional sample is tested, if the total number of deviations is less than 3% of the total expanded sample (sum of initial sample and additional sample), no further test procedures are necessary. If after expanding the sample, the total number of deviations exceeds 3% of the total expanded sample, please contact CRS for additional guidance.

9. Tests of AttributesWhen performing the procedures described in the Protocol, it is important that the Auditor understand the objectives and nature of the tests to be performed. Each of the procedures addressed in Section III is designed to test specific attributes, and the objectives of the procedures are noted at the beginning of each testing section. Each transaction or sampling unit may need to be tested for multiple attributes and any exception will need to be evaluated in


accordance with the guidance noted above in Use of Sampling Techniques. Auditors who do not understand the objectives and nature of the tests to be performed should contact Green-e® Energy staff for clarification.

10. Principal Testing to Be PerformedThe principal testing to be performed by the Auditor will be reading, vouching, comparing and recalculating information provided to the Auditor by the Participant. See Section III of the Protocol for specific tests to be performed.

11. Applying General Procedures to Specific CircumstancesThis document provides guidance and specific examples of the procedures to be performed in providing CRS with assurances as to the accuracy and completeness of Participants’ Annual Verification Submissions to CRS. The nature and complexity of supply and sale transactions differ among companies participating in Green-e® Energy. Additionally, accounting systems and transaction data structures of each of the Participants will vary along with the types of information and reports internally available. Accordingly, the following requirements described in Section II and III of the Protocol are not intended to be all inclusive, but rather represent the minimum standards to be applied in performing tests of the documentation trail associated with the information submitted to CRS by the Participants. Judgment will need to be applied in order to execute the agreed-upon procedures engagement under each specific circumstance.

III. SPECIFIC AUDIT REQUIREMENTS Section III directs the Auditor to perform a number of procedures for the following purposes listed below, and to prepare an Agreed-Upon Procedures Report. Test electricity and REC supply; Verify eligibility of the renewable MWh in products; Test renewable MWh sales; Verify balance of supply and sales/use; Substantiate that Participant made no specific purchases and/or generation of nuclear

energy for the Green-e® Energy certified product; and Verify completeness of verification submittal.

Additional procedures for renewable energy products wholly or partially supplied by RECs: Verify that the electrical energy associated with RECs was delivered into the electric power

system or consumed at the site of generation by a grid-connected end-user of electricity and was not marketed or otherwise represented as renewable electricity.

Additional procedures for certified Green Pricing and Competitive Electricity products: Verify sales by distribution utilities.


Additional procedures for certified Green Pricing products: Verify that product pricing is based on cost-based rates; and Verify that during the RY being verified the utility was in compliance with rules imposed on

the Green Pricing program by the utility’s oversight body.

General Notes on Performing the Audit and Preparing the Agreed-Upon Procedures Reporta. The Agreed-Upon Procedures Report must be produced by specifically responding to each

review step in the Protocol in page 13 through the end of Section III on page 27. Each review step for the Auditor is followed by a box as shown below: Step III.x.x was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

Each review step is numbered. This Section of the Protocol is Section III, so the first step for Worksheet 1 review is “III.1.1”. In the box that corresponds to each review step, the Auditor must check one of the three checkboxes indicating whether the step was completed as written or whether the step did not apply. Also, the Auditor must provide explanation of any exceptions, any notes on how the Auditor’s review differed from the specified instructions, and any reasons that “N/A” was checked because the step did not apply.

Once the Auditor has responded to each review step, the Auditor must submit the report to Green-e® Energy through the verification software in PDF format. A scan of a printout is acceptable, as is a PDF generated with an electronic signature. A hardcopy does not need to be mailed to Green-e® Energy staff. Do not mail a printout of the full report.

b. If review of documents provided by Participant and the review of this Protocol lead you to believe that certain data requests in the verification software are applicable to the Participant’s sales of a Green-e® Energy certified product despite being filled in as ‘Not Applicable’, not being filled in, or otherwise omitted by the Participant, note this in an Additional Auditor Notes field at the end of a relevant audit section.

c. If Green-e® Energy staff find that the Agreed-Upon Procedures Report is not completely filled out, the Participant’s Annual Verification Submission will not be considered complete until the Agreed-Upon Procedures Report is satisfactorily revised to reflect that the full audit was conducted in accordance with this Protocol. Auditors that do not provide a satisfactory Agreed-Upon Procedures Report will not be eligible to be listed on the list of auditors on the Green-e® website (http://www.green-e.org/auditors.html), may be removed from that list if the Auditor has appeared on it in the past, may be placed on probation, and may be barred from performing future Green-e® Energy audits, at the sole discretion of Green-e® Energy staff. For Auditors placed on probation, should the quality of the subsequent year’s Agreed-Upon Procedures Reporting not improve, the Auditor may be deemed unacceptable to perform the Green-e® Energy Annual Verification Audit thereafter.


[Insert letterhead graphic, or delete this text if printing on letterhead]

Independent Auditor’s Report on Applying Agreed-Upon Procedures

To the [Board of Directors or Other Highest Oversight Body of Participant Company] of[Participant Company for which Audit was Performed]and the Center for Resource Solutions

We have performed the procedures enumerated below, which were agreed to by [Participant Company for which Audit was Performed] (the “Company”) and the Center for Resource Solutions (the specified parties), to verify the Company’s compliance with annual reporting requirements of the Center for Resource Solutions’ Green-e® Energy program for the year that ended December 31, 2018. The Company’s management is responsible for the Company’s compliance with the annual reporting requirements of the Center for Resource Solutions’ Green-e® Energy program. The sufficiency of these procedures is solely the responsibility of the specified users of the report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures and associated findings are as follows:

1. . . . .

2. . . . . (describe procedures and findings)

3. . . . .

This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. We were not engaged to and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on the compliance of the annual reporting requirements of the Center for Resource Solutions’ Green-e® Energy program. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to the Company and the Center for Resource Solutions.

[Add any additional paragraph(s) to describe other matters.]

This report is intended solely for the information and use of the specified users listed above and is not intended to be and should not be used by anyone other than those specified parties.

1. Supply and Supporting Documentation

Applicability and Intent of the Section

Copyright © February 2019 Center for Resource Solutions. All rights reserved. Last updated Feb. 20, 2019.

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All Green-e® Energy Participants with certified products in 2018 must show that they have purchased or generated enough renewable MWh to support their certified products, verify eligibility of facilities supplying renewable MWh to Participant, and provide data to prevent double counting of renewable MWh by certain purchasers of electricity that has been separated from RECs.

Background and Important Reminders for the Section Supply that has already been allocated to prior RY sales, even if it meets the 21-month

generation period of eligibility for RY2018, should not be listed. Supply reported as eligible on the Participant’s prior RY’s software submission may only be listed in the software system for RY2018 if that supply was not allocated to sales in the prior RY.

A number of audit steps will require you to review attestations and/or Tracking System Reports. It may save time during the audit to conduct all steps pertaining to attestations during a single review of all attestations rather than reviewing all attestations once per audit step and therefore reviewing all attestations multiple times. All attestations and Tracking System Reports are available under their respective sections and also under Audit Participant Data>>View or Download Supporting Documents.

All data, attestations and other supporting documents are stored in Green-e® Energy’s online verification software system. For many audit steps, you may want to have multiple web browser windows open with your client’s data submission available, so that you can flip between screens without having to navigate back and forth between screens.

EIA (Energy Information Administration) numbers for generation facilities should be the Plant or Facility ID number, and not the Utility ID number; the EIA assigns unique numbers for both.

In some cases, a facility may have registered in a tracking system partway through 2018, such that part of the generation was not issued RECs in a tracking system and some was issued RECs in a tracking system. In these cases, treat the generation from the period prior to joining a tracking system as one facility and the generation from the period after joining the tracking system as separate facilities for the purposes of Steps III.1.6-9.

Software System Pages needed: Facility Information table (Audit Participant Data>>View Participants Data>>Supply, also

available in the “View All” table, Audit Participant Data>>View Participants Data>>View All)

Generation Information table (Audit Participant Data>>View Participants Data>>Supply>>View Generation; accessed by clicking on “View Generation” on the Facility Information table)

Supporting Documents (Audit Participant Data>>View or Download Supporting Documents) to view all submitted Supporting Documents, or to view Supporting Documents for specific facilities go to (View Participants Data>>Supply>>View Generation>>Supporting Documents)

Participant’s Products, Notes & Customers (Audit Participant Data>>Participant's Products, Notes & Customers)


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Audit Procedures for the Section1. Obtain from the Participant:

if the Participant sold any Green-e® Energy certified products in the year prior to the current Reporting Year (RY), obtain the completed Annual Verification Submission from that prior RY

contracts or other company records that provide information on the name and other identifying characteristics of the generating facility, the amount of renewable MWh purchased/generated from it, the date of generation, and the wholesale supplier from which the MWh were purchased

copies of meter readings and the most recent meter certifications for all generators listed that the Participant owns that are supplying MWh toward Green-e® Energy certified products in the RY being verified

log-in information for the Participant’s accounts in all Tracking Systems (unless the Participant will be logging in and guiding you through their accounts)

Step III.1.1 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

2. For every renewable electricity or REC purchase transaction listed in the supply section of the verification software system, the Participant must have documentation demonstrating the transfer of ownership of renewable MWh from generator through to Participant, even if ownership of the REC has passed through many parties before reaching the Participant. If the Participant is the generator, Participant must still supply attestations for the amount of generation they are claiming toward sales this RY. Note if the Participant has not supplied attestations in a manner consistent with Appendix D, which describes which documentation must be supplied in various scenarios. If any renewable electricity or REC purchase transaction is missing proof of supply delivery documentation, this step cannot be completed and you may not submit this Agreed-Upon Procedures document to Green-e® Energy staff. Note any exceptions.Step III.1.2 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

3. For all facilities on the Facility Information table (Audit Participant Data>>View Participants Data>>Supply) that have listed generation after June of 2018 must be registered in an approved tracking system unless:

The entire facility has an aggregated nameplate capacity less than or equal to 10 MW, or

The facility is located on property owned by the retail electricity user claiming the RECs/renewable energy or has a “direct-line connection,” that user is claiming all RECs generated by the facility during the period of certification, and that all generation is validated by attestations and 3rd party verification records, or

The Participant’s total certified sales volume is less than or equal to 10,000 MWh for that reporting year. In this case, another tracking system accountholder must retire supply on behalf of the Participant’s certified sales, or

The facility (or Participants) using output from the facility in Green-e® Energy certified transactions provides to Green-e® Energy an independent 3rd party


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verification of the facility, including, but not limited to, its total output and sales agreements, to verify no double selling has occurred, in accordance with Green-e® Energy verification procedures.


4. For all facilities on the Facility Information table (Audit Participant Data>>View Participants Data>>Supply) that have “No” listed under “Approved Tracking Attestation” and that have a tracking system name under “Tracking System,” check that each such facility has a corresponding attestation uploaded in the software system. This can be checked through the aggregate “Supporting Documents” page (Audit Participant Data>>View or Download Supporting Documents) for all facilities or through the Generation Information table for an individual facility. Note any exceptions. Such facilities must provide Tracking Attestations or Generator, Wholesale or Small Generator Attestation showing the full chain of custody; remind Participant of this requirement if any facilities are noted in this step. Step III.1.4 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

5. For all attestations, only official Green-e® Energy forms with a modification date of January 2007 or later (as listed in the lower left of each page) will be accepted. Current versions for comparison are available at http://green-e.org/verif_docs.html. Note any exceptions.Step III.1.5 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

6. For each facility without a Tracking System name on the Facility Information table, check that the facility was not registered in a tracking system during the period of generation claimed as supply. Use the following map to determine the applicable tracking system: https://www.green-e.org/glossary#tracking. Check the following tracking system generator lists:

ERCOT: https://www.texasrenewables.com/publicReports/rpt1.asp

MIRECS: https://portal2.mirecs.org/myModule/rpt/myrpt.asp?r=111

MRETS: https://app.mrets.org/reports/public/projects

NAR: https://narenewables2.apx.com/myModule/rpt/myrpt.asp?r=111

NCRETS: https://portal2.ncrets.org/myModule/rpt/myrpt.asp?r=111

NE-GIS: https://www1.nepoolgis.com/myModule/rpt/myrpt.asp?r=111

NYGATS: https://nygats.ny.gov/ng/Report/getdto_view_Report_PublicProjectsAll

PJM-GATS: https://gats.pjm-eis.com/gats2/PublicReports/RenewableGeneratorsRegisteredinGATS

WREGIS: https://portal2.wregis.org/myModule/rpt/myrpt.aspx?r=111

You may need to click through several screens or perform a search within the public report. List any facilities that appear on one of the above sites and contact the Participant about providing a Tracking System Report.


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https://portal2.wregis.org/myModule/rpt/myrpt.aspx?r=111

https://gats.pjm-eis.com/gats2/PublicReports/RenewableGeneratorsRegisteredinGATS

https://nygats.ny.gov/ng/Report/getdto_view_Report_PublicProjectsAll

https://www1.nepoolgis.com/myModule/rpt/myrpt.asp?r=111

https://portal2.ncrets.org/myModule/rpt/myrpt.asp?r=111

https://narenewables2.apx.com/myModule/rpt/myrpt.asp?r=111

https://portal2.mirecs.org/myModule/rpt/myrpt.asp?r=111

https://www.texasrenewables.com/publicReports/rpt1.asp

https://www.green-e.org/glossary#tracking

For facilities identified through this step as being in a Tracking System during the period of claimed generation, facility’s Tracking ID must be added to Participant’s Facility Information table.

Once a Tracking System Report is obtained for the supply, apply Step III.1.11 to the supply and Step III.1.10 to the Tracking System Report. If MWh from facility identified as being in a Tracking System were purchased by Participant in a Green-e® Energy certified wholesale transaction, then in some cases, a Tracking System Report is necessary; consult Section III of Appendix E.

Step III.1.6 was performed: Yes. No. N/A. Exceptions, Notes, Reason for “No” or “N/A”:

7. For each facility that is not in a Tracking System, if the Participant purchased the MWh from the generator or is the owner of the generating facility, examine the Generator Attestation or Small Generator Attestation for each purchase and/or amount of generation recorded on the respective Generation Information table. If the Participant owns the generation facility, Participant is still required to supply a Generator Attestation or Small Generator Attestation listing Participant as Seller and as Purchaser.

Use Appendix D for general guidance on attestation types and chain of custody documentation.

From the attestation, note all facilities that have a First Operation Date prior to 1/1/2004, and all facilities that list any date under Date of Repowering or Upgrade.

Confirm that the generating facility name, generator location (state), EIA or QF ID number, nameplate capacity, first operational date, and fuel/resource type listed in the Facility Information table match what is listed on the Generator Attestation.

If the fuel/resource type is biomass-based, check that either “Gaseous Biomass” is entered as the resource type in the Facility Information table for landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases, or “Non-gaseous Biomass” is entered for wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass. Confirm that Section IV of the Generator Attestation, “Additional statement required for and applicable to biomass facilities only,” has been completed.

Note if the Participant is not named in these documents as the Purchaser of the renewable MWh.

Confirm that the date of generation listed in the Generation Information table matches what is listed in Generator Attestation or Small Generator Attestation. The MWh volume listed on the attestation must be greater than or equal to the MWh volume listed in “MWh” column in the Generation Information table. If the Participant completed the “MWh listed on attestation” column in the Generation Information table, then the MWh volume listed on the attestation must match this value.

In the Declaration Section of the attestation (Section III), confirm that if the “renewable electricity (electricity bundled with renewable attributes)” box is marked, then “Elec” is listed in Facility Information table. If “renewable attributes only” is marked, confirm that “REC” is listed in the Facility Information table.

Confirm that the “No” box is checked in the cap and trade section of the Generator Attestation (Declaration, Section III). If the “Yes” box is checked, note the cap-and-trade program, refer Participant to footnote 20 of the Standard for Canada and the US and contact Green-e® Energy staff immediately.


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Confirm that each attestation is signed by an agent of the Seller. Confirm that the entity listed under “If Seller is providing only RECs to Purchaser and

selling the associated electricity to a utility or load-serving entity, please write the name of the utility or load-serving entity here” on the attestation matches the entity listed in the Facility Information table.

For all facilities listing a resource type of Non-Gaseous Biomass, check to see if the Participant has completed and uploaded a “Non-Gaseous Biomass Generator Attestation for Electricity and RECs” appended with other facility attestation documents.

Note any exceptions.Step III.1.7 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

8. For each facility that is not in a Tracking System, if the Participant purchased renewable MWh from another Green-e® Energy Participant in the form of a Green-e® Energy certified wholesale product, examine the Wholesale Attestation for each purchase and/or amount of generation recorded on the Facility Information table. If “Yes” is indicated for “Selling as Green-e® Energy certified Wholesale?” in the rightmost column of the sales table on the Wholesale Attestation that also lists the Participant as the purchaser, check that the Seller is listed in Appendix F. If the Seller is listed in Appendix F, then the Wholesale Attestation is the only document needed for the chain of custody for the renewable MWh listed on the attestation. If the Seller is not listed in Appendix F, or if “No” is indicated for “Selling as Green-e® Energy certified Wholesale?” in the rightmost column of the sales table on the Wholesale Attestation, apply Step III.1.9 to the supply listed on the attestation instead of this Step III.1.8.

Use Appendix D for general guidance on attestation types and chain of custody documentation.

From the attestation, note all facilities that have a First Operation Date prior to 1/1/2004, and all facilities that list any date under Date of Repowering or Upgrade.

Confirm that the Wholesale Attestation names the Participant as the purchaser of the RECs or renewable electricity.

Confirm that the generating facility name, facility ID number, nameplate capacity, first operational date, and fuel/resource type listed in the Facility Information table match what is listed on the Wholesale Attestation.

If the fuel/resource type is biomass-based, check that either “Gaseous Biomass” is entered in the Facility Information table for landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases, or “Non-gaseous Biomass” is entered for wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass.


Confirm that the date of generation and volume of MWh in the Generation Information table match what is listed in the Wholesale Attestation. The MWh volume listed on the attestation must be greater than or equal to the MWh volume listed in the Generation Information table.

In the Declaration Section of the Wholesale Attestation (Section II), confirm that if the “electricity bundled with renewable attributes” is marked, then “Electricity” is listed in


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the Purchase type column of the Facility Information table. If “renewable attributes only” is marked, confirm that “REC” is listed in the Facility Information table.

Confirm that each attestation is signed by an agent of the Seller. Note any exceptions.Step III.1.8 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

9. For each facility that is not in a Tracking System, and for which the Participant purchased renewable MWh in the form of a non-Green-e® Energy certified wholesale product, examine the Wholesale Attestation(s), and Generator Attestation for each purchase and/or amount of generation recorded on the Generation Information table. If “No” is indicated, or the field is blank, for “Selling as Green-e® Energy certified Wholesale?” in the rightmost column of the sales table on the Wholesale Attestation that lists the Participant as the purchaser, complete this Step III.1.9. If “Yes” is indicated for “Selling as Green-e® Energy certified Wholesale?” in the rightmost column of the sales table on the Wholesale Attestation, complete Step III.1.8 instead. Use Appendix D for general guidance on attestation types and chain of custody

documentation. From the attestations, note all facilities that have a First Operation Date prior to 1/1/2004,

and all facilities that list any date under Date of Repowering or Upgrade. Trace and confirm complete documentation of the chain of custody of the renewable

MWh:oObtain a completed and signed Wholesale Attestation that lists the Participant

as the purchaser and the Seller as the entity listed as the Supplier in the Facility Information table.

oObtain one or more completed and signed Wholesale Attestations, one for each transfer of ownership of the renewable MWh from the generator, all intermediaries, and the Participant. Each purchaser named on the preceding attestation must be the seller on the next attestation, until the Participant is listed as the purchaser on the final attestation.

oObtain a completed and signed Generator Attestation from the generator that names the seller in the last Wholesale Attestation as the purchaser of the renewable MWh.

Confirm that the generating facility name, facility ID number, nameplate capacity, first operational date, and fuel/resource type listed in the Facility Information table match what is listed on each Wholesale Attestation and the Generator Attestation.

If the fuel/resource type is biomass-based, check that either “Gaseous Biomass” is entered in the Facility Information table for landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases, or “Non-gaseous Biomass” is entered for wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass. Confirm that Section IV of the Generator Attestation, “Additional statement required for and applicable to biomass facilities only,” has been completed.


Confirm that the generator location (state or province) listed on the Facility Information table matches the Generator Attestation.


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Confirm that the date of generation and volume of MWh listed in the Generation Information table match what is listed in each Wholesale Attestation and the Generator Attestation. The MWh volume listed on the attestation must be greater than or equal to the MWh volume listed in the Generation Information table.

For the Wholesale Attestation that names the Participant as the purchaser, in the Declaration Section of the Wholesale Attestation (Section II), confirm that if the “electricity bundled with renewable attributes” is marked, then “Electricity” is listed in the Purchase Type column of the Facility Information table. If “renewable attributes only” is marked, confirm that “REC” is listed in the Facility Information table.



selling the associated electricity to a utility or load-serving entity, please write the name of the utility or load-serving entity here” on the Generator Attestation matches the entity listed as the Entity Purchasing Electricity in the Facility Information table.


10. Examine each of the Participant’s Tracking System Reports and for all MWh sold from each facility in a Tracking System, as indicated by a valid Tracking System name appearing on the Facility Information table for the facility or as identified in Step III.1.6, perform the following steps. For guidance on what documentation is appropriate if a question arises, refer to Appendices D and E, covering attestations and tracking system reports, respectively.

Facility Information table Confirm that the following information on the Facility Information table corresponds to

what is listed on the Tracking System Report: generating facility name (Facility), facility ID number (Tracking System ID), and fuel/resource type (Resource Type). Note any exceptions.

Review the facility online date listed in the Tracking System Report and note all facilities that have a First Operation Date prior to 1/1/2004.

If the fuel/resource type listed on the Tracking System Report is biomass-based, check that the fuel/resource type matches the corresponding Resource Type on the Facility Information table according to the following breakdown: “Gaseous Biomass” includes landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases; “Non-gaseous Biomass” includes wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass.

Generation Information table Confirm that the date of generation listed on the Generation Information table for each

facility (Audit Participant Data>>View Participants Data>>Supply>>View Generation; accessed by clicking on “View Generation” on the Facility Information table) matches


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what is listed in the Tracking System Report, and that the corresponding volume of MWh on the Generation Information table is less than or equal to what is listed in the Tracking System Report in aggregate for that month (in the case of ERCOT, confirm by quarter of generation).

For facilities with “Yes” under the “Approved Tracking Attestation?” column on the Facility Information table, confirm that the date of generation listed in Month/Quarter and Year on the Generation Information table falls between the Start Date and Exp. Date listed on that facility’s row on the downloadable list of approved facilities on the Audit Protocol and Training page within the verification software.

If a facility is in a Tracking System for the period of generation listed on the Generation Information table, but the Tracking System column on the Facility Information table does not show a tracking system name, the Participant will still have to provide a valid Tracking System Report for the generation.

Confirm that the MWh listed under “Total Generation Volume (MWh)” on the Facility Information table for tracked facilities were retired or transferred to another account holder according to the Tracking System Reports. “Pending” or “Active” transactions are not acceptable. Confirm that the “Retirement Reason” or “Memo” field of each retirement includes, at minimum, the terms “Green-e® Energy” and “2018”. See Appendix E for required Tracking System memo language for each Tracking System.

Participants may provide the Serial Numbers of RECs in Tracking Systems, in the Generation Information table. Providing serial numbers is an optional step in the software system, but if this information may be useful in conducting the audit if it is provided. Comparison of provided serial numbers to Tracking System Reports is not required under this Protocol.

General Note if Participant is not named as the owner of the Tracking System account that

generated the Tracking System Report. If Participant is not named as the owner of the account, note whether Participant is named as the retirer or transferor of the amount of MWh on the Tracking System Report. All Participants that purchased and sold RECs that are tracked in a tracking system must have their own tracking system account. In certain circumstances, Green-e® Energy may allow RECs to be retired for a certified retail product in the tracking system account of a different Green-e® Energy participant, rather than the account of the participant offering the retail product. Participants must receive approval from a Green-e® Energy representative to qualify for this exception.

If Participant is not named as the owner of the Tracking System account that generated the Tracking System Report, and the Participant has received approval from Green-e® staff for RECs to be retired in the tracking system account of a different Green-e® Energy participant, Participant must supply chain of custody documentation back to the point of retirement. Therefore, note whether Participant has provided one or more completed Wholesale Attestations that match the retirement and that document the chain of custody starting from REC retirement on the Tracking System Report.

Log into Participant’s corresponding Tracking System account, or view an employee of Participant accessing the account, and compare each Tracking System Report to data in Participant’s corresponding Tracking System account.


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The Participant does not need to provide Tracking System documentation showing transfer of the RECs into Participant’s account.

Note any exceptions discovered at any point during this step.Step III.1.10 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

11. For all facilities that have “No” listed under “Approved Tracking Attestation” and that have a tracking system name under “Tracking System” and for which Participant submitted Generator, Wholesale or Small Generator Attestations (this includes those facilities identified in Step III.1.4 as using Generator, Wholesale or Small Generator Attestation), AND for all facilities identified in Step III.1.6 as being in a tracking system, AND for facilities that have “Yes” listed under “Approved Tracking Attestation” and that Participant purchased as a Green-e® Energy certified wholesale purchase and did not provide a Tracking System Report: Use Appendix D for general guidance on attestation types and chain of custody

documentation. From the attestations, note all facilities (and the corresponding dates) that have a First

Operation Date prior to 1/1/2004, and all facilities that list any date under Date of Repowering or Upgrade.

Trace and confirm complete documentation of the chain of custody of the renewable MWh:

oObtain a completed and signed Wholesale Attestation that lists the Participant as the purchaser and the Seller as the entity listed as the Supplier in the Facility Information table.

oObtain one or more completed and signed Wholesale Attestations, one for each transfer of ownership of the renewable MWh from the generator, all intermediaries, and the Participant. Each purchaser named on the preceding attestation must be the seller on the next attestation, until the Participant is listed as the purchaser on the final attestation.

oObtain a completed and signed Generator Attestation from the generator that names the seller in the last Wholesale Attestation as the purchaser of the renewable MWh.

If no Generator Attestation is provided, and the earliest Wholesale Attestation in the chain of custody both lists a Seller that is listed in Appendix F and indicates “Yes” under “Selling as Green-e® Energy certified Wholesale?” in the rightmost column of the sales table, then no attestation documents further up the chain of custody than such a Wholesale Attestation are necessary. This is because the upstream seller of a certified wholesale transaction will provide documentation further up the chain of custody.

Confirm that the generating facility name, facility ID number, nameplate capacity, first operational date, and fuel/resource type listed in the Facility Information table match what is listed on each Wholesale Attestation and the Generator Attestation.

If the fuel/resource type is biomass-based, check that either “Gaseous Biomass” is entered in the Facility Information table for landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases, or “Non-gaseous Biomass” is entered for wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass. Confirm that Section IV of the Generator Attestation,


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“Additional statement required for and applicable to biomass facilities only,” has been completed.

Confirm that the generator location (state or province) listed on the Facility Information table matches the Generator Attestation.

Confirm that the date of generation and volume of MWh listed in the Generation Information table match what is listed in each Wholesale Attestation and the Generator Attestation. The MWh volume listed on the attestation must be greater than or equal to the MWh volume listed in the Generation Information table.

For the Wholesale Attestation that names the Participant as the purchaser, in the Declaration Section of the Wholesale Attestation (Section II), confirm that if the “electricity bundled with renewable attributes” is marked, then “Electricity” is listed in the Purchase Type column of the Facility Information table. If “renewable attributes only” is marked, confirm that “REC” is listed in the Facility Information table.



selling the associated electricity to a utility or load-serving entity, please write the name of the utility or load-serving entity here” on the Generator Attestation matches the entity listed as the Entity Purchasing Electricity in the Facility Information table.

Note any exceptionsStep III.1.11 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

12. For all facilities that have “No” listed under “Approved Tracking Attestation” and that have a tracking system name under “Tracking System,” and for which Participant submitted a Tracking Attestation (this includes those facilities identified in Step III.1.4 as using Tracking Attestations), perform the following steps:Facility Information table Confirm that the following information on the Facility Information table corresponds to

what is listed on the Tracking Attestation: generating facility name (Facility) facility ID number (Tracking System ID), fuel/resource type (Resource Type), nameplate capacity (Capacity), and online date (First Operation Date). Note any exceptions.

Note all facilities (and the corresponding dates) that have a First Operation Date prior to 1/1/2004, and all facilities that list any date under Date of Capacity Upgrade or Repowering on the Tracking Attestation.

If the fuel/resource type listed on the Tracking Attestation is biomass-based, check that the fuel/resource type matches the corresponding Resource Type on the Facility Information table according to the following breakdown: “Gaseous Biomass” includes landfill gas (LFG), wastewater methane, digester gas, biogas, and other biogenic gases; “Non-gaseous Biomass” includes wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops or any other liquid or solid biomass. Confirm that Section III of the Tracking Attestation, “Additional statement required for and applicable to biomass facilities only,” has been completed.


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Confirm that the date of generation listed in the Generation Information table falls between the Start Date and End Date listed on the Tracking Attestation.

Confirm that the “No” box is checked in the cap and trade section of the Tracking Attestation (Facility and Registration Information, Section I). If the “Yes” box is checked, note the cap-and-trade program, refer Participant to footnote 20 of the Standard for Canada and the US and contact Green-e® Energy staff immediately.

Confirm that each attestation is signed by an agent of the Seller or Account Manager as indicated on the Tracking Attestation.

Confirm that the entity listed under “If Seller is providing only RECs to Purchaser and selling the associated electricity to a utility or load-serving entity, please write the name of the utility or load-serving entity here” on the Generator Attestation matches the entity listed as the Entity Purchasing Electricity in the Facility Information table. List all such facilities by name and Tracking System ID in the “Exceptions, Notes…” field below.


13. This Step III.1.13 applies to MWh for which no Tracking System Report is required. Use the Sampling Guidelines listed in Section II.8 of this Protocol to determine the appropriate sample size for the number of entries and apply this step for those entries in the sample. For this step, the sampling unit is purchases and/or generation quarters from a facility. Compare each selected item per the Generation Information and Facility Information tables to a copy of the billing invoice that contains information regarding renewable MWh purchased and/or generated, date of generation (the date of generation can be in terms of month/year), and resource type. Note, it may be necessary to also examine a copy of the contract or other documents to test this information (specify in the Auditor’s Agreed-Upon Procedures Report if the contract or other documents were used). Note any exceptions. This step is not necessary for purchases and/or generation for which a Tracking System Report was provided from Participant’s account or naming Participant specifically in the retirement reason / memo.Step III.1.13 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”: Population Size (required, must fill in): Sample Size (required, must fill in):

14. For all purchases sampled in Step III.1.13, examine the purchase date on each billing invoice. Report as an exception any purchases after June 3, 2019. For supply in a Tracking System reported toward RY2018 sales, if the Date of Submission to the Auditor (Reporting Tools>>Audit Status) is after June 3, 2019, also examine the date of transfer to the Participant on each Tracking System Report (this can be done in conjunction with Step III1.10); if you find any transfers occurring after June 3, 2019, review the corresponding supply contract for the date of signature. If the date of signature is after June 3, 2019, note as an exception. If the Participant is submitting the Annual Verification Submission beyond the June 3, 2019 verification submission deadline, check all purchase dates (not just a sample) and all dates of REC receipt in Tracking Systems.Step III.1.14 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:


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15. Check that all facilities have a date on or after 1/1/2004 in the First Operation Date column of the Facility Information table. For all facilities with a date before 1/1/2004 in that column or with “Yes” in the Re-Powered column, check that there is a Repowering Letter signed by a Center for Resource Solutions employee on file with CRS, either uploaded by Participant in the verification software or otherwise indicated as approved in the verification software. If letter has been uploaded by Participant, confirm that information on the submitted letter agrees with corresponding facility information in the verification software system: Facility Name, First Operation Date, Re-Powered Date, and Resource Type. Note any exceptions.


16. Obtain from the Participant a copy of the Green-e® Energy Attestation from Program Participant (which is Appendix G of the Getting Started Guide). Make sure this attestation is included with the final Annual Verification Submission. Note any exceptions. Step III.1.16 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

17. Check the Participant’s Products, Notes & Customers (Audit Participant Data>>Participant's Products, Notes & Customers) for any additional audit steps to be performed. Describe here what steps were performed. Note any exceptions.


Additional Auditor Comments

2. Green-e® Energy Certified Retail Sales

Background and Important Reminders for Retail Sales Review For companies with offices in multiple locations, count the customer location as where they

were billed. If offices of the same company in different locations bought certified products separately, count them as separate customers.

Note that while the Verification Tool uses the term “Sales” in this section, in the case of Participants with contracts with CRS to certify their purchases and generation, such as the Participants that are the subject of this Protocol, “Sales” in this case should be interpreted as the Participant’s use or allocation of renewable MWh.

Software Pages Needed for These Steps Retail Sales Details for each retail product for which they reported certified sale: Audit

Participant Data>>View Participant’s Data>>Retail Sales>>Sales Details, also available on the “View All” table (Audit Participant Data>>View Participant’s Data>>View All)


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Participant’s Products, Notes & Customers: Audit Participant Data>>Participant's Products, Notes & Customers

Total Retail SalesApplicability and Intent of the SectionThis section of the Protocol applies to all participants who had a certified product in the given calendar year. It does not apply to wholesale sales.

The intent of “Retail Sales” reporting is to verify the volume of purchases and generation allocated to the Participant in RY2018.

Audit Procedures for Retail Sales1. Obtain from Participant:

documentation supporting the number of customers buying each product, with type of customer (residential vs. non-residential / commercial), the MWh sold to each customer, and the customer location (state or province)

Tracking System Retirement ReportsStep III.2.1 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”:

2. Using copies of internal reporting documents that the Participant used to provide retail user data, recalculate the amount of MWh of use and number of customers by product for each customer type, residential and non-residential and agree this to the retail sales reported by state in the respective tables in “Audit Participant Data>>View Participant’s Data>>Retail Sales>>Sales Details”. Note any exceptions.


3. Review customer MWh allocations detailed in the internal company documents. For this step, the sampling unit is defined as an allocation of an amount of RECs to the Participant or to a facility owned or controlled by Participant or Participant’s subsidiaries.

i. Confirm the total amount of MWh used in facilities owned or controlled by Participant or Participant’s subsidiaries to which the Participant will be allocating an amount of RECs.

ii. Confirm the percentage of the total amount of MWh used in the above facilities that the allocated RECs will cover and that this percentage does not exceed 100% of total use.

iii. Confirm that total allocations do not exceed total retirements. Compare total MWh reported in company records and on the Non-Residential Retail Sales table to a copy of the Tracking System Retirement Reports and any other necessary records (specify in the report what, if any, other record was used). Note any exceptions.

iv. For those REC allocations that specified a generation facility up front, track the total MWh from each specified facility and each allocation, and check that each facility and a sufficient number of MWh from the specified generation dates appear on the Facility Information table and / or aggregated Generator Information tables. Note any exceptions.


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Step III.2.3 was performed: Yes. No. N/A.Exceptions, Notes, Reason for “No” or “N/A”: Population Size (required, must fill in): Sample Size (required, must fill in):

Additional Auditor Comments on Retail Sales


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I declare that I am qualified to perform the Green-e® Energy audit, as I am (check one):

an external auditor and CPA; or

working for the Company and am a Certified Internal Auditor (CIA) in good standing with the Institute of Internal Auditors.

Based on the Green-e® Energy Audit Protocol and the results of the Agreed-Upon Procedures, [Auditor Company Name] asserts that the Company has:

NO EXCEPTIONS with regard to its compliance of the Green-e® Energy verification reporting requirements put forth in the Annual Verification Instructions and Annual Verification Protocol; or

EXCEPTIONS with regard to its compliance of the Green-e® Energy verification reporting requirements put forth in the Annual Verification Instructions and Annual Verification Protocol, and these exceptions are listed in the Agreed-Upon Procedures Report.

[Date Attesation Signed]Signature Date of Report[Name of Lead Auditor] [Title of Lead Auditor]Printed Name Title[Auditor Company Name] [Address of Auditor Company]Auditor Company Name: Business Address:

*If more than one auditor conducted the Agreed-Upon Procedures Report (AUPR), the manager of the audit procedures should sign above. The names of those who were involved in the AUPR may be listed below:

[Names of Additional Auditors]


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APPENDIX A: GLOSSARY OF TERMS

Agreed-Upon Procedures Report: The report supplied to CRS prepared by the Auditor detailing the results of the annual verification audit by performing the procedures stipulated in the Green-e® Energy Annual Verification Audit Protocol.

Biomass: Eligible biomass resources include: landfill gas, digester gas, plant-based agricultural, vegetative and food processing waste, bioenergy crops, clean urban waste wood, and mill residues; see the Standard for Canada and the US for the full range of eligible types. For the purposes of verification reporting, Gaseous Biomass includes landfill gas, wastewater methane, digester gas, biogas, and other biogenic gases, and Non-gaseous Biomass includes wood waste, sawmill waste, black liquor, agricultural waste, ethanol, fuel crops and the like.

Customer: The party who has purchased a Green-e® Energy certified product from the Participant.

Co-firing: When two or more fuels are used in a single generator together to generate electricity. For Green-e® Energy, co-firing comes into play when an eligible fuel type is used together with an ineligible fuel, requiring calculations to show how much electricity was derived from the eligible fuel. Co-firing facilities must be pre-approved by Green-e® Energy before they may be used to supply certified sales. See Section II.B of the Standard for Canada and the US.

Electronic Tracking System (“Tracking System”): A regional, software-based system in place to issue RECs from the renewable generation located in its area, track REC ownership transaction between parties, and record REC retirement. Approved Tracking Systems are listed in Appendix E.

Eligible Renewable Resource: As defined by the Green-e® Energy Standard for Canada and the US. These include wind, solar photovoltaic, geothermal, low-impact hydropower, and many (but not all) types of biomass.

Geothermal: Natural heat and steam from within the earth that is captured to generate electric power. Geothermal energy can also be used for space heating or industrial steam.

Generator: A facility that physically generates electricity. The term is also used here to denote the owner of such a facility. If a generator claims to be eligible under the Green-e® Energy Standard for Canada and the US, it must have legal documentation verifying the name, address, capacity, resource type and operational date and that information must bear out such a claim.

Green-e® Energy Annual Verification Submission (“Annual Verification Submission”): The collected, completed and audited data and documents required to be submitted annually to the Center for Resource Solutions as part of Green-e® Energy certification. These documents include: The Agreed-Upon Procedures Report, as well as all required, completed data and documents loaded into the verification software system.

Green-e® Energy Renewable Energy Standard for Canada and the United States (“Standard for Canada and the US”): The governing document for Green-e® Energy eligibility and certification. It is available on the Green-e® Energy website at https://www.green-e.org/programs/energy/documents.

Green-e® Energy Annual Getting Started Guide (“Guide”): Provides instructions for Participants in Green-e® Energy on how to fill in the Green-e® Energy Verification Bulk Upload


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Worksheet and what materials to assemble for the Auditor to complete the Agreed-Upon Procedures Report.

Green-e® Energy Annual Verification Audit Protocol (“Protocol”): Provides instructions for the Auditor on the procedures to perform in order to verify a Participant’s annual sales and supply of renewable energy and/or RECs.

Hydroelectric: A technology that produces electricity from moving water that turns a generator.

Kilowatt-hour (kWh): The most commonly-used unit of measure telling the amount of electricity consumed over time. It means one kilowatt of electricity supplied for one hour.

Megawatt-hour (MWh): One thousand kilowatt-hours. The common denomination for RECs.

New Renewable: The term “new” is defined to include any eligible renewable facility beginning operation after January 1, 2004, or repowered after that date. Only new renewable resources are eligible to participate in Green-e® Energy certified products. See Section II.E of the Green-e® Energy Standard for Canada and the US.

Participant: An entity offering for sale at least one Green-e® Energy certified REC or electricity product to retail or wholesale customers.

Product: The renewable electricity or REC that a Participant offers to sell to customers.

Renewable Energy Certificate (REC): Renewable electricity generation can be split into two parts: the electricity produced by a renewable generator and the renewable “attributes” of that generation. These renewable attributes are sold separately as renewable energy certificates (RECs). One REC is issued for each megawatt-hour (MWh) unit of renewable electricity produced. RECs contain specific information about the renewable energy generated, including where, when, at what facility, and with what type of renewable resource. Purchasers of RECs are buying the renewable attributes of those specific units of renewable energy in order to re-combine them with electricity from the grid and have the sole claim to using the output of a particular renewable generator.

Renewable MWh: A term used in this document to refer to RECs and/or renewable electricity.

Renewable Portfolio Standard: A state or federal level policy that requires that a minimum amount (usually a percentage) of electricity supply provided by each supply company is to come from renewable energy.

Reporting Year: The period beginning January 1 in the sales year being reported or the date the Participant began selling its Green-e® Energy certified product, and ending on December 31 of that year.

Reporting Year 2018 Annual Verification Submission Timeline and Deadlines (“Verification Timeline”): A document provided to Participants that details the timeline, due dates and penalties associated with preparing and submitting all verification materials in Reporting Year 2018.

Repowering / Repowered Facility: A generation facility that has replaced enough of it generation equipment to be equivalent to a brand new facility. To be eligible under the Standard for Canada and the US, a repowered facility must meet certain criteria, submit paperwork to Green-e® Energy, and be pre-approved before being used to supply Green-e® Energy certified sales. See Section II.E.2 of the Standard for Canada and the US.


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Retail Product: A renewable energy product sold to residential, non-residential/commercial or industrial customers, or to any customer that will use the purchase to make specific renewable energy claims about its electricity use. This is as opposed to a wholesale customer, who resells the renewable energy without making its own renewable energy use claims.

Solar: Sources that use solar radiation to produce electricity. Photovoltaic technologies convert sunlight directly into electricity. Solar thermal electric facilities use the heat of the sun to generate electricity.

Vintage: The vintage of a renewable MWh is the date that the renewable electric generation was measured by the system operator or utility meter at the generator site. A Green-e® Energy certified renewable energy product may only include RECs or renewable electricity generated in the calendar year in which the product is sold, the first three months of the following calendar year, or the last 6 months of the prior calendar year. For Reporting Year 2018 generation must have taken place between July 1, 2017 and March 31, 2019 in order to be eligible.

Wholesale Product: A renewable energy product sold to a customer that will resell the renewable energy. This is opposed to a retail customer who keeps or retires the renewable energy in order to make renewable energy claims about their electricity use.

Wholesale Supplier: A company that sells renewable MWh to a Participant. This company may be the renewable generator or may be a third party marketer or broker. May also be called a wholesaler or wholesale marketer.

Wind: A renewable resource using wind to turn a turbine to generate electricity.


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APPENDIX B: DOCUMENTS AND INFORMATION NEEDED BY THE AUDITOR AND GREEN-E® ENERGY

The following is a list of information that Participants need to provide to their Auditor and Green-e® Energy. Depending on the complexity of a Participant’s sales, supply and audit, not all of the documents may be necessary; they should be tailored to each particular audit engagement as reports and information will vary. If you are using a different Auditor this year or are a new Participant, you will need to send us your Auditor’s contact information in advance to [email protected] so that they can obtain a secure login to the software system.

Table B-1 Documents and Information Needed by the Auditor and Green-e® Energy

DocumentSubmit to Auditor

Submit to Green-e® Energy via verification software

Electronic Tracking System Report (“Tracking System Report”): If a facility is in a Tracking System, then reports generated from Participants’ Tracking System accounts must be used, in accordance with Appendix E. The intent of such reports is to show that the RECs are either retired in the Tracking System or transferred to another accountholder such that the Participant cannot re-sell the RECs.

Log-in information for your accounts in all Tracking Systems.

Green-e® Energy Attestation from Program Participant: This document is signed by the Participant being audited. Through it, the Participant attests that all information provided with the verification submission is accurate, and makes a number of specific attestation statements governing Green-e® Energy certified sales and reporting. It is included as Appendix G of the Guide.

Product Content Label: The disclosure to customers of the annual mix of resources used to supply a Green-e® Energy certified product for the RY being verified. Product Content Labels can take two forms: Prospective, which display the projected resource mix that a Participant will supply to customers, and is distributed to customers at the beginning of a RY; and Historic, which reflect the actual renewables delivered, based on purchases and allocations of renewables throughout the RY, and which are required to be sent to all customers of a Green-e® Energy certified product by June 30th of the year following the RY they represent. Both must be supplied to the Auditor for all Utility Green Pricing Program, Single Mix REC Products, and Single Mix Electricity Products (i.e. retail residential products).


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Green-e® Energy Attestation from Generator Participating in a Tracking System (“Tracking Attestation”): For generators registered with an approved electronic Tracking System and whose renewable electricity and/or RECs are being used in a Green-e® Energy certified product, this attestation must be completed and submitted to Center for Resource Solutions. Completion of the Tracking Attestation demonstrates that these generators meet the eligibility criteria in the Standard for Canada and the US. CRS will maintain a list of generators who have completed the Tracking Attestation and determined to be eligible: https://www.green-e.org/tracking. If a facility is listed on the downloadable list of approved facilities on the “Verification Documents” tab within the verification software tool, and covers the period of generation claimed, then the Participant does not need to include a copy in its Annual Verification Submission. See Appendix E for further details on the intent and use of this form.

Green-®e Energy Renewable Generator Registration Form and Attestation (“Generator Attestation”): For renewable electricity or RECs purchased and/or generated from facilities not in a Tracking System for products sold in the RY being reported, Participant will need one copy filled out by each generator of renewable MWh that Participant purchased from, whether Participant purchased directly from the generator or through one or more wholesalers, unless the participant is purchasing a Green-e® Energy certified wholesale product. If Participant owns the generation facility supplying renewable MWh for a Green-e® Energy certified product, Participant must complete and supply a copy of the Generator Attestation for those renewable MWh. See Appendix D for instructions.

Green-e® Energy Renewable Attestation from Wholesale Provider of Electricity or RECs (“Wholesale Attestation”): For facilities not in a Tracking System: For renewable electricity or RECs purchased for products sold in the RY being verified, Participant will need one copy filled out by each wholesaler from whom it purchased these renewables, and from each wholesaler that was part of the chain of ownership of these renewables. See Appendix D for instructions.


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Green-e® Energy Attestation for Renewable Energy Certificates (RECs) Delivered From a Small Solar/Wind/Hydro Electric Power Facility (“Small Generator Attestation”): For renewable energy facilities 10 kW or below in capacity, the Small Generator Attestation serves the same function as the Generator Attestation and is to be used in the same way. See Appendix D for instructions.

Contracts, billing statements, other company records, or other third party documentation that provide information on the name and other identifying characteristics of the generating facility, the amount of renewable MWh purchased/generated from it, the date of generation, and the wholesale supplier from which the MWh were purchased.

For any generating facilities owned by the Participant, meter reading documentation made by a third party (i.e., scheduling coordinator or meter data management agent) supporting the generation amounts, as well as a copy of the most recent third party meter certification.

Emissions information for any specific purchases or generation of non-eligible resources (other than nuclear, which is not allowed as a specific purchase). If you have bought specific electricity to be paired with RECs and sold as a renewable electricity product, the electricity purchased must not have emissions greater than the default system mix the green pricing customer would have otherwise received. If you have bought specific electricity for this purpose, you must document that the emissions rates of the electricity are low enough. Contact Green-e® Energy staff for appropriate forms; the forms are not distributed to all Participants as they apply to few Participants.

Name of the purchaser of the undifferentiated electricity / null power from a facility that sold you RECs, if available; this should be available on supply attestations.

Documentation from Green-e® Energy stating the eligibility of any repowered facility.

Documentation from Green-e® Energy stating the eligibility of any co-firing facility.

Documentation of Low-Impact Hydropower Institute (LIHI) certification for hydropower facilities in the U.S. if certification is not listed on the LIHI website, www.lowimpacthydro.org.

Documentation of EcoLogo certification for hydropower facilities in Canada if certification is not listed on the EcoLogo website.


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http://www.lowimpacthydro.org/



Bills of sale or invoices, and sales contracts to wholesale customers. Where the Participant has sold renewable MWh for resale as part of a wholesale transaction, a copy of the contract between Participant and customer and any other information necessary for the Auditor.

Internal reporting documents that indicate retail sales by month, which is any report from the Participant that contains the detail of sales per customer for each product sold and that was used to complete sales data in the verification software system. The Auditor will need to have the data sorted by customer class (residential vs. non-residential / commercial), by product, and by customer location (State or Province). Includes Participant company billing statements, invoices to customers, evidence of paid invoices, and/or delivery receipt letters, as well as MWh sold to each customer, and the location of each retail customer.

Contracts for sale of certified products may also be necessary if such contracts call for very specific renewable resources.

Any other company records that contain information on customers and their purchases of Green-e® Energy certified products.

For utility green pricing products only, a copy of documentation that verifies that the Green-e® Energy certified green pricing products sold are cost-based rates.

Green-e® Energy Verification Bulk Upload Worksheet: (Optional) A single worksheet to be filled in by the Participant with data on the supply for and sales of Green-e® Energy certified products, which will be verified by the Auditor. An accompanying secure, password-protected FTP site with all backup documentation is also required. This method is only recommended if the Participant is sourcing from a large number of facilities and has an existing data collection system that can export data into the format required in the bulk upload worksheet.

The previous RY’s verification submission, if your company was a Green-e® Energy Participant in the previous RY.


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Regional Greenhouse Gas Initiative (RGGI) Reports: for renewable MWh generated in Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island or Vermont, and sold into any of those states. All reports submitted to RGGI state environmental oversight bodies to substantiate sales into those RGGI states. Responses from RGGI state environmental oversight bodies responding to receipt and review of submitted reports, if responses have been received. See Appendix C for more details.

Michigan Attestation Form: Proof of retirement of Michigan Incentive Renewable Energy Credits (IRECs) appropriate to match sales of Michigan generation and a Michigan Attestation Form, available on the Green-e® Energy website.

Arizona REST Report: for renewable MWh generated in Arizona, Green-e® Energy Participants using RECs generated in the footprint of Affected Utilities subject to the REST (including, but not limited to, Arizona Public Service [APS] and Tucson Electric Power [TEP]) must demonstrate through the REST report or ACC statement that only utility owned RECs were used for REST compliance and that subtracted-out MWh were not included in the compliance evaluation.

Details of sales made to customers participating in Green-e® Marketplace.

Details of sales made to customers using their Green-e® Energy certified purchase for LEED green building certification, in particular the number of such sales and sales volume per customer by location.

Summary spreadsheet if Green-e® Energy certified sales are being made through Electric Vehicle (EV) Charging Stations.

For utilities using a hub-and-spoke model, a summary spreadsheet of records from each distributor of their sales of the Green-e® Energy certified product.


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Attestation for the Retirement of California Greenhouse Gas Allowances and proof that greenhouse gas allowances have been retired for renewable energy supply from facilities in California or delivering electricity to the California grid. This document is required for allowances not retired by the California Air Resources Board (ARB) through the Voluntary Renewable Energy Program (VREP). Depending on the final VREP application materials posted by the ARB, an additional Green-e® Energy attestation may be required of VREP users; this will be announced once ARB posts its VREP application materials. In addition to VREP documentation, information for all California related retirements must be provided for each generator providing renewable MWh on the Green-e® Energy California Allowance Retirement Worksheet for RY 2018. See also Appendix D of this Guide.

Attestation for Specific Electricity Purchases and Emissions Reporting, to be completed if you sell a Green-e® Energy certified renewable electricity product that is less than 100% certified renewables, and are supplying the non-certified electricity portion with electricity other than your default electricity service resource mix. You will upload this document to the Supporting Documents page.


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APPENDIX C: INTENTIONALLY OMITTED


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APPENDIX D: ATTESTATION REQUIREMENTS

RequirementsAll renewable MWh purchased or generated to supply Green-e® Energy certified sales must have one or more attestation documents in place showing the chain of custody of those MWh from the generator all the way through to the Green-e® Energy Participant. These attestations are designed to summarize salient information from contracts transferring ownership of the MWh, and attestations are not themselves contracts or replacements for contracts.

Attestations used to support Green-e® Energy certified sales must be on forms created by Green-e® Energy. These forms are available at http://www.green-e.org/verif_docs.html. Each Green-e® Energy attestation has a modification date listed in the lower left of each page; only Green-e® Energy attestation forms with a modification date of January 2007 or later will be accepted. The only exceptions are attestation forms that were: written into a contract prior to this date; or, granted specific approval by Green-e® Energy staff prior to data submission in the verification software.

Attestation Reminders and Tips The use of Tracking System Reports and Tracking Attestations must adhere to the Tracking

System Requirements in Appendix E. Each type of attestation is defined in Appendix B. Participant company must be named as purchaser on the attestation(s) provided by the seller

of renewable MWh (the entity supplying renewable MWh to the Participant) All attestations must be completely filled out, including the Declaration section, and signed by

an agent of the Seller listed on the attestation. One set of attestations per facility will be uploaded to the verification software system. Each

facility that is not on the downloadable list of approved tracked facilities must have one electronic file to cover all attestations for all quarters of generation by the facility. If there is more than one attestation for the facility, combine all attestations for the facility into one PDF or zip file. Do not scan or zip all attestations for several facilities into one file; each facility should have its own separate file.

Note that all contracts for supply must be signed, dated, and executed no later than June 3, 2019; later contracts will not be accepted. Delivery of the supply must be taken by Participant in the form of transfers through a Tracking System or receipt of completed Green-e® Energy attestation forms by this date also. This means that the price and volume of the supply must be finalized and specified in the contract at or before this time, and all facility information related to contracted supply must be provided to Participant on or before June 3, 2019. You will not be able to submit the verification submission and Agreed-Upon Procedures Report to Green-e® Energy staff without all proof of supply delivery documentation.

Placeholder data will not be accepted in the software. Facility, supply, sales or other data entered as “variable”, “to be determined”, “unknown at time of submission” or the like may be grounds for non-acceptance of the Verification Submission, at the discretion of Green-e® Energy staff, until such data is corrected and specified in the verification software.


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http://www.green-e.org/verif_docs.html

Example Chains of Custody and Attestations for Facilities not on the Approved Tracked FacilitiesIf you purchased directly from the renewable generator or used output from a generation facility you own2, you must submit: A completed and signed Generator Attestation

If you purchased renewable MWh from another Green-e® Energy Participant in the form of a Green-e® Energy certified wholesale product, you must submit: A completed and signed Wholesale Attestation that has “Yes” in the rightmost column of the

generation table and that lists a Green-e® Energy Participant as the seller.

If you purchased renewable MWh in the form of a non-Green-e® Energy certified wholesale product, you must submit: A completed and signed Generator Attestation; and One or more completed and signed Wholesale Attestations, one for each transfer of ownership

of the renewable MWh from the generator, all intermediaries, and the Participant. Each purchaser named on the preceding attestation must be the seller on the next attestation, until you are listed as the purchaser on the final attestation.

If you purchased and/or self-generated renewable MWh from a renewable energy generator with a nameplate capacity less than or equal to 10 kW, you must submit: A completed and signed Small Generator Attestation.

Facilities in Tracking SystemsSee Appendix E for further details of using Tracking Systems to substantiate purchases and sales, and for instructions on what types of attestations should be used with tracked facilities.

Additional Facility and Transaction DocumentationThe Auditor will be checking attestation forms to ensure that the characteristics of the facility comply with the Standard for Canada and the US, and that repowering and/or co-firing approval has been granted. Please have any additional documentation needed ready for your Auditor, such as letters from Green-e® Energy and documentation of Low-Impact Hydropower Institute certification.

Facilities in Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island and Vermont also require additional documentation, described in Appendix C.

Michigan facilities require a form to be filled out related to the retirement of incentive renewable energy credits (IRECs).

CaliforniaFacilities located in California or that delivered electricity to the California grid also require additional documentation showing that the appropriate number of greenhouse gas allowances have been retired. See Appendix A.5 of the Green-e® Energy Standard for Canada and the US

2 If the Participant owns the generator, Participant should be listed as Seller and Purchaser on the Generator Attestation.


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for further details on eligibility of certain generation facilities in or directly delivering electricity to California.

I. Facilities eligible for the California Air Resources Board (ARB) through the Voluntary Renewable Energy Program (VREP) (ties to section 1 of Appendix A.5 of the Standard for Canada and the US): Materials are be posted at http://www.arb.ca.gov/cc/capandtrade/renewable/renewable.htm and Green-e® Energy will update and recirculate this Guide soon after. Once the materials are posted, they must be completed and submitted to the ARB and to Green-e® Energy. The ARB also publishes a VREP guidance document available at http://www.arb.ca.gov/cc/capandtrade/guidance/chapter7.pdf.

II. Facilities first online between January 1, 1999 and June 30, 2005 but otherwise VREP eligible (ties to section 2 of Appendix A.5 of the Standard for Canada and the US): Retirement of allowances must be demonstrated through the “Compliance Instrument Tracking System Service” (CITSS) emissions allowance tracking system, and a Attestation for the Retirement of California Greenhouse Gas Allowances must be provided along with this report. The Attestation for the Retirement of California Greenhouse Gas Allowances must be signed by the entity retiring the allowances in CITSS on behalf of the first Green-e® Energy certified transaction of the MWh from such a facility. All California allowance related documentation must be submitted through “Other Support Documents” on the “All Supporting Documents” page in the Verification software.

In addition to VREP documentation, information for all California related retirements must be provided for each generator providing renewable MWh on the Green-e® Energy California Allowance Retirement Worksheet for RY 2018.

All attestations and forms for California are available in the Verification Software on the “Verification Documents” page of the Participant interface.


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http://www.arb.ca.gov/cc/capandtrade/guidance/chapter7.pdf

http://www.arb.ca.gov/cc/capandtrade/renewable/renewable.htm

APPENDIX E: USING TRACKING SYSTEMS IN VERIFICATION

These requirements govern the use of electronic Tracking Systems toward the annual verification requirements for participants in Green-e® Energy.

Attestations Used with Tracking SystemsFor generators registered with an approved electronic Tracking System and whose renewable electricity and/or RECs are being used in a Green-e® Energy certified product, one or more attestations must be completed and submitted to Center for Resource Solutions. One available attestation is the “Green-e® Energy Attestation from Generator Participating in a Tracking System” (“Tracking Attestation”). Tracking Attestations can be submitted at any time for review by Green-e® Energy staff. Approval of a Tracking Attestation demonstrates that the generator meets the eligibility criteria in the Standard for Canada and the US. CRS maintains a list of generators who have completed the Tracking Attestation and determined to be eligible for Green-e® Energy: https://www.green-e.org/tracking. A downloadable list of these facilities for RY2018 is available on that page and is also located in the “Verification Documents” tab of the verification software tool. If a facility is listed on this downloadable list and covers and period of generation claimed, then Participant does not need to include a copy of the Tracking Attestation in its Annual Verification Submission.

If the facility is registered in a Tracking System and the facility is not listed on the 2018 static list of approved tracked facilities as being eligible for the period of generation claimed, then generators of renewable certificates3 that are retired in Tracking Systems must sign one of two forms:

Tracking Attestation4 This form, available on the Green-e® Energy verification documents website, will have the Generator attest to the eligibility of all generation put onto the Tracking System over a certain period. Each such generator only needs to fill out and submit to Green-e® Energy the Tracking Attestation once every two to three years, which will apply to all renewable certificates from that facility during the period the Tracking Attestation is in effect. Trades made between the minting / issuance of RECs and the retirement of RECs do not require Generator and Wholesale Attestations, since the Tracking Attestation covers the RECs as they are issued in the Tracking System, a Tracking System Report shows that the RECs were retired, and the Tracking System software and operating rules prevent double-selling and disaggregation of RECs within the Tracking System. The Tracking Attestation must be submitted to Green-e staff through the following online form: https://www.tfaforms.com/4652008.

Generator Attestation A Generator Attestation may be filled out for a specific number of MWh generated over a certain period and transacted through the Tracking System, if the generator does not wish to fill out a Tracking Attestation. RECs listed on a Generator Attestation used in this way must still be transacted through the Tracking System as well, with all intermediate REC owning parties

3 ‘Renewable certificates’ is the terminology commonly used within Tracking Systems to refer to RECs and/or renewable electricity, and throughout this document the term refers to renewable energy/RECs in your Tracking System account that you are specifically using for Green-e® Energy certified sales.4 Generators that have signed the Tracking Attestation will be listed on the Green-e® website at http://www.green-e.org/tracking_attests_recd.html


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https://www.tfaforms.com/4652008

completing Wholesale Attestations, and the Participant providing Green-e® Energy with retirement and / or transfer reports from the Tracking System to substantiate sales. Note that this method of using Tracking Systems results in an increased amount of paperwork necessary to compile, review and submit, reducing the effectiveness of using a Tracking System in the first place. Therefore, use of a Tracking Attestation is recommended instead of using a Generator Attestation in this way.

Tracking System ReportsIn all cases, Participants using Tracking Systems to substantiate sales must submit Tracking System Reports with their verification submission. Tracking System Reports must show that the RECs you sold were either confirmed as being retired on behalf of a specific customer or on behalf of Green-e® Energy certified sales for a particular RY, or show that the RECs have been transferred from you to another customer with an account in the same Tracking System. Pending transactions are not acceptable. Reports only showing transfer of RECs into your account are not sufficient.

For Tracking Systems that will not have Reports available by June 3, such as NE-GIS and PJM-GATS, Tracking System Reports must be uploaded to the verification software system within 10 business days after the settlement period for first quarter 2019 trading closes. In addition, Auditors will note a Participant’s use of any Q1/2019 renewable MWh in the Agreed-Upon Procedures Report. Tracking System Reports ultimately submitted must match with renewable supply entered in the verification data software.

Microsoft Word or Excel versions of the Tracking System Reports are not acceptable.

To facilitate the review of your Tracking System Reports by your Auditor and Green-e® Energy Staff, it is highly recommended that you present only RY2018 retired or transferred RECs in the Tracking System, and sort them by facility ID number.

I. Procedures for Using Individual Approved Tracking Systems to Verify Sales Made to a Customer Outside of a Tracking System

This section applies to sales of renewable certificates from your Tracking System account to a customer that does not have their own Tracking System account. For instructions on renewable certificates sold to a customer that does have their own Tracking System account, see section II of this Appendix.

Renewable certificates retired for Reporting Year 2018 sales must include the Reporting Year in the memo field/reason code.

NEPOOL Generation Information System (NE-GIS) Transfer renewable certificates into your Reserve Account. In the Transferee text field type “Green-e® Energy RYXXXX”, where XXXX is year in which

the renewable certificates are being sold and the Reporting Year for which verification is being conducted. This is in addition to listing the name of the entity you transferred the RECs to.


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NEPOOL GIS will retire the certificates in your Reserve Account at the end of the trading period

Generate a Report of all renewable certificates with this Reason code that are listed in the Green-e® Energy verification software system as supply for the Reporting Year in question.

Obtain Tracking Attestation(s) from each generator of renewable certificates retired toward the particular RY.

Auditor will compare this Report to your actual NE-GIS account.

New York Generation Attribute Tracking System (NYGATS) Transfer renewable certificates into a Retirement Sub-Account that you have created

specifically for Green-e® Energy, which automatically retires them. In the Retirement Reason text field type “Green-e® Energy RYXXXX”, where XXXX is year

in which the renewable certificates are being sold and the Reporting Year for which verification is being conducted.



Auditor will compare this Report to your actual NYGATS account.

North American Renewables Registry (NAR) Transfer renewable certificates into a Retirement Sub-Account that you have created

specifically for Green-e® Energy, which automatically retires them. Select one of the following options:

o “Used by the Account Holder for a Utility Green Pricing Program:” o “Used by the Account Holder for a Green Electricity Product:” o “Used by the Account Holder for a REC-Only Product:”

In the Reason drop-down select ‘Program Compliance’ In the ‘Additional Details’ field type “Green-e® Energy RYXXXX”, where XXXX is year in

which the renewable certificates are being sold and the Reporting Year for which verification is being conducted.



Auditor will compare this Report to your actual NAR account.

North Carolina Renewable Energy Tracking System (NC-RETS) Transfer renewable certificates into a Retirement Sub-Account that you have created

specifically for Green-e® Energy, which automatically retires them. Select “Other” In the Retirement Reason text field type “Green-e® Energy RYXXXX”, where XXXX is year

in which the renewable certificates are being sold and the Reporting Year for which verification is being conducted.



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Auditor will compare this Report to your actual NC-RETS account.

Michigan Renewable Energy Certification System (MIRECS) Transfer renewable certificates into a Retirement Sub-Account that you have created

specifically for Green-e® Energy, which automatically retires them. Select one of the following options:

o “Used by the Account Holder for a Utility Green Pricing Program:” o “Used by the Account Holder for a Credit Only Product:” o “Other:” Define reason in text box provided

Define reason in the ‘Additional Details’ text box provided In the ‘Additional Details’ field type “Green-e® Energy RYXXXX”, where XXXX is year in

which the renewable certificates are being sold and the Reporting Year for which verification is being conducted.



Auditor will compare this Report to your actual MIRECS account.

Midwest Renewable Energy Tracking System (M-RETS) Transfer renewable certificates into a Retirement Sub-Account that you have created

specifically for Green-e® Energy, which automatically retires them. Select the retirement reason: “Used by the Account Holder for a Green-e® Energy Certified

Voluntary Market Sale”. Designate one of the following Retirement Reasons: Green Electricity Product, REC Only or Utility Green Pricing Program and follow all other steps in this section.



Auditor will compare this Report to your actual M-RETS account.

PJM Generation Attribute Tracking System (PJM-GATS) Transfer renewable certificates into a Reserve Sub-Account that you have created

specifically for Green-e® Energy, which automatically reserves them. In the Retirement Reason drop-down, select “Other” and type “Green-e® Energy RYXXXX”,

where XXXX is year in which the renewable certificates are being sold and the Reporting Year for which verification is being conducted.

o When used for compliance with Maryland’s RGGI reporting rules, this field must also contain “MD RGGI Program”. See Appendix C, especially Table C2.

Generate a Report of all renewable certificates with this Reservation code that are listed in the Green-e® Energy verification software system as supply for the Reporting Year in question.



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Auditor will compare this Report to your actual PJM-GATS account.

Texas’ Statewide Tracking System (ERCOT)5

Create a new account in ERCOT specifically for Green-e® Energy renewable certificates.6

Retire renewable certificates in this account. In the Memo text field type “Green-e® Energy RYXXXX”, where XXXX is year in which the

renewable certificates are being sold and the Reporting Year for which verification is being conducted.

Generate a report of renewable certificates retired in the account with this Memo field entry that are listed in the Green-e® Energy verification software system as supply for the Reporting Year in question.


Auditor will compare this Report to your actual ERCOT account.

Western Regional Energy Generation Information System (WREGIS) Transfer renewable certificates into a Retirement Sub-Account that you create specifically for

Green-e® Energy, which automatically retires them. Select one of the following options:

o “Used by the Account Holder for a Utility Green Pricing Program:” o “Used by the Account Holder for a Green Electricity Product:” o “Used by the Account Holder for a REC-Only Product:”o “Other”o For California facilities or facilities delivering electricity to the California grid and that

qualify for the Voluntary Renewable Energy Program set-aside: Use the “Used by the Account Holder for Other Regulatory Program”

retirement reason, and select “CARB” in the “Additional Details” box. In the Retirement Reason text field text field type “Green-e® Energy RYXXXX”, where XXXX

is year in which the renewable certificates are being sold and the Reporting Year for which verification is being conducted.


Obtain Tracking Attestation(s) from each generator of renewable certificates retired toward the particular RY. Auditor will compare this Report to your actual WREGIS account.

II. Certified Wholesale Transactions and Transactions within a Tracking System

For Green-e® Energy certified transactions made within a Tracking System between a Green-e® Energy Participant’s Tracking System account and the Tracking System account of the

5 For non-wind facilities located in Texas, additional Tracking System requirements may apply, due to a state law that went into effect on January 1, 2008, that increases the potential for double counting of the benefits of renewable energy. Please see Appendix A of the Green-e® Energy Standard for Canada and the US for details before transacting non-wind renewable MWh that you wish to get Green-e® Energy Certified that come from facilities located in Texas. 6 ERCOT does not have sub-accounts. New accounts require approximately one week to come online.


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Participant’s customer, the following procedures must be followed. These steps are not specific to a particular Tracking System, but apply to all Tracking Systems.

Transfer the renewable certificates to the customer’s Tracking System account. Within your Transaction History, Account History or equivalent, display the renewable

certificates transferred to the customer’s Tracking System account. The following information about the transferred renewable certificates must be displayed:

o Generator name;o Facility ID numbero Generation date;o Renewable resource type;o Transfer date;o Number of MWh transferred and the corresponding ID numbers of the renewable

certificates transferred; o Name of customer; o Green-e® Energy RYXXXX, where XXXX is year in which the renewable certificates

are being sold and the Reporting Year for which verification is being conducted; ando That the transfer was confirmed, not simply initiated.

Generate a Report showing the Transaction History, Account History or equivalent. Obtain Tracking Attestation(s) from each generator of renewable certificates retired toward

the particular RY. Auditor will compare this Transaction History Report, Account History Report or equivalent

report to your actual Tracking System account.

III. Wholesale Supply Sourced from a Generator in a Tracking System when the Buyer does not have a Tracking System Account

In some cases, marketers of renewable energy will buy wholesale supply from a Tracking System when the marketer does not have their own account in the Tracking System. This requires that the RECs purchased from the Tracking System be prevented from further transfer within the Tracking System, so that the marketer can be assured that they have the sole claim to those RECs, and the demonstration of the chain of custody once the RECs have left the Tracking System. Unfortunately, this scenario leads to extra verification paperwork, since paperwork from the Tracking System and traditional paper attestations from every holder of the RECs are required.

Green-e® Energy strongly recommends that Tracking Systems be used as intended, and that Participants receiving tracked renewable certificates have an account in the Tracking System. The steps below are to be used only when that is not possible for a given transaction due to the Participant not having a Tracking System account.

In this case, the Participant must supply Green-e® Energy with the following documentation as part of its verification submission:

1. Attestation(s), either:a. Tracking Attestation from the generator, for a period covering the generation period

of the RECs so to the Participant.


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i. If the facility is listed on the RY2018 downloadable list of approved tracked facilities available in the “Verification Documents” page of the verification software and at https://www.green-e.org/tracking, and the generation being used as supply by the Participant falls between the dates in the Start Date and End Date columns, then a Tracking Attestation is not necessary and the requirement to provide an attestation is satisfied.

ORb. Generator, Wholesale and Small Generator Attestations documenting the full chain

of custody (see Appendix D) from the generator through to the entity retiring RECs in the Tracking System on behalf of the Participant. This entails the generator signing a Generator Attestation naming the first purchaser of RECs, then than purchasers signing a Wholesale Attestation naming the next purchaser, and so on until the Participant is named as a purchaser. Each attestation in the chain must be provided.

AND

2. The entity selling the RECs out of the Tracking System to a Participant without a Tracking System account (“Selling Entity”) must retire the RECs in the Tracking System, and use the appropriate Retirement Reason (or, in some Tracking Systems, show the RECs as Reserved; see above details by Tracking System) to indicate that the RECs are not being retired for a claim, but rather to be traded outside the Tracking System. The Participant must procure from the Selling Entity the following retirement-related documentation. Either:

a. A Tracking System Report that includes the name of the buyer in the Retirement Reason code (and follows all other Retirement Reason rules above), along with all of the other required language mentioned in Section I of Appendix E for the Tracking System being used; OR

b. If the buyer name is left out of the Retirement Reason but the rest of the Retirement Reason rules in Section I above are followed, provide a Wholesale Attestation naming the buyer as the buyer of those RECs retired in the Tracking System, and also provide a Tracking System Report with all of the required language mentioned in Section I above, minus the buyer’s name. The number of MWh, facility name generation date, and other types of information listed on both the Wholesale Attestation and the Tracking System Report must match. The serial numbers of the retired renewable certificates should be written on the Wholesale Attestation prior to attestation signature so that the attestation and Report can be matched easily.

If another Participant is the Selling Entity, and the sale made to the purchasing Participant is a Green-e® Energy certified wholesale transaction, then the Selling Entity Participant is responsible for submitting all upstream documentation in 1 and 2 above (attestations, Tracking System Reports) as part of their own verification submission, and the purchasing Participant must provide Green-e® Energy with at least the following: a completed Wholesale Attestation that


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https://www.green-e.org/tracking

1. Names the Selling Entity Participant as the seller and the purchasing Participant as the buyer; AND

2. Indicates “Yes” in the “Selling as Green-e® Energy Certified Wholesale?” column in the table on page 2 of the attestation.

In this way Green-e® Energy will receive chain of custody documentation tracking the certified wholesale back to the generator without duplicate documentation, through the two Participant’s separate verification submissions, allowing for verification of the purchasing Participant’s purchase.


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APPENDIX F: COMPANIES PARTICIPATING IN GREEN-E® ENERGY IN 2018

Common abbreviations, former names and/or other business names are noted in parentheses. If using the Bulk Upload Worksheet, these names must be entered exactly as they appear below.

3Degrees Inc. L'Oreal3 Phases Renewables LG&E and KU EnergyAEP Energy, Inc. Liberty PowerAgera Energy Luminant Energy Company, LLCAggressive Energy MCE Clean EnergyAlameda Municipal Power MC SquaredAlliant Energy MidAmerican Energy CompanyAmbit Energy Holdings, LLC MidAmerican Energy ServicesAmeren Missouri Moffett Solar 1, LLCAmsterdam Capital Trading B.V. (ACT Commodities Inc) MP2 EnergyApple Inc. NativeEnergyAustin Energy Natural Capital PartnersAvangrid Renewables (Iberdrola) NextEra Energy ResourcesAzalea Solar, LLC North American Power and Gas, LLC (NA Power)Blue Delta Energy Northern Indiana Public Service Company (NIPSCO)BlueRock Energy, Inc. NRG Business SolutionsBlue Spruce Energy Services OneEnergy RenewablesBonneville Environmental Foundation (BEF) Pacific Gas and Electric (PG&E)Calpine Energy Solutions, LLC PacifiCorpCarbon Solutions Group (CSG) Peninsula Clean EnergyCBL Markets Pine Gate Renewables, LLCChampion Energy Marketing, LLC Platte River Power Authority (PRPA)City of Palo Alto Utilities Plymouth Rock EnergyCleanChoice Energy (formerly Ethical Electric) Portland General Electric (PGE)CleanPowerSF Powerex CorpCommunity Energy, Inc. Puget Sound Energy (PSE)Constellation NewEnergy Sacramento Municipal Utility District (SMUD)Consumers Energy Company San Diego Gas & Electric (SDG&E)Cypress Creek Renewables Santee CooperDirect Energy Schneider ElectricDominion Energy Virginia Seattle City LightDTE Electric Silicon Valley Clean EnergyDynegy Silicon Valley Power (SVP) - City of Santa ClaraEast Coast Power & Gas, LLC Southern California Edison (SCE)ECOHZ South Plains Wind Energy II, LLCEDF Energy Services SP Cactus Flats Wind Energy LLCENGIE Resources Spring Power and GasFirst Climate Markets AG Steelcase


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FirstEnergy Solutions Corp. Sterling PlanetGood Energy Stream EnergyGreenlight Energy Group LLC Swiss Carbon AssetsGreen Mountain Energy Tennessee Valley Authority (TVA)Green Power EMC TXU EnergyIdaho Power Company Vivorex LLCIndianapolis Power & Light Company (AES) We EnergiesJ.P. Morgan Ventures Energy Corporation Westar Energy, Inc.JEA Western Farmers Electric CooperativeJust Energy WGL Energy Services, Inc.Kiwi Energy WPPI Energy


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